SolvedCRYPTO22254 | Cryptoassets for individuals: Capital Gains Tax: pooling examples: example 4 - interaction of same day rule with section 104 pool
From HM Revenue & Customs · Cryptoassets Manual
This example shows how to the same day rule and a part disposal of the section 104 pool interact.
Daniel holds 8,000 token D in a section 104 pool. He spent a total of £1,000 acquiring them, which is his pooled allowable cost.
On 31 January 20XX Daniel enters into the following transactions:
Disposal of 5,000 token D for £500.
Acquisition of 4,000 token D for £320
Acquisition of 1,000 token D for £75
Acquisition of 1,000 token D for £70
Disposal of 2,000 token D for £142
Acquisition of 500 token D for £35
Daniel’s disposals both take place on the same day, so they are treated as a single disposal of 7.000 token D for £642. Daniel’s acquisitions all take place on the same day, so they are treated as a single acquisition of 6,500 token D for £500.
Daniel’s acquisition and disposal take place on the same day, so the acquisition is matched with the disposal. The remaining 500 token D are treated as a part disposal of the section 104 pool. Daniel will need to work out the gain on his disposal as follows:
| Consideration | £500 + £142 | £642 |
|---|---|---|
| Less allowable costs – same day (6,500 token D) | £320 + £75 + £70 + £35 | (£500) |
| Less allowable costs – S104 | £1,000 x (500 / 8,000) | (£63) |
| Gain | £79 |
Daniel will need to reduce his section 104 pool to 7,500 token D and total allowable costs of £937:
| Date | Quantity of token D | Pooled allowable costs |
|---|---|---|
| Opening balance | 8,000 | £1,000 |
| 31/01/20XX | (500) | (£63) |
| Closing balance | 7,500 | £937 |